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Generally speaking, in the late 18th and 19th centuries a petition, unlike a memorial, included a prayer (e.g., petition of John Smith praying that his claim be granted). Memorials also express opposition to ('remonstrate against') some pending action. In modern usage, there is no apparent difference between a memorial and a petition, and petition has become the commonly accepted generic term. A similar document transmitted to Congress by a legislative body such as a State legislature takes the form of a resolution and is sometimes termed a memorial.